Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more
The IRS is making good on its promise to step up enforcement on large partnerships that issue more than 100 annual K-1s and have more than $100 million in assets. As noted in this Latham Client Alert, the IRS’s renewed focus...more
The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more
The Third Circuit challenges the long-held view that the timing requirements for Tax Court review of a notice of deficiency preclude any extension or delay of the filing deadline.
Culp v. Commissioner is the first case in...more
The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions.
Key Points:
..Notice 2017-10...more
Economic aid legislation will likely result in increased scrutiny of certain industries, similar to investigations that followed relief efforts in the 2008 financial crisis.
Key Points:
..The CARES Act creates multiple...more
Updated guidance relieves most tax deadlines, provides new procedures for claiming tax relief, and addresses communications with the IRS during the widespread shutdown.
...more
Notice 2020-18, expanded by Notice 2020-20, provides welcome economic relief from filing and payment obligations for certain federal taxes; however, traps for the unwary exist.
Tax Deadline – Key Points:
..On March 20,...more
News release details operational changes and additional administrative relief for taxpayers facing uncertainty due to COVID-19.
Key Points:
..The IRS is prioritizing taxpayer and IRS personnel safety and security with...more
Notice 2020-18 provides welcome economic relief from filing and payment obligations for certain federal income taxes; however, traps for the unwary exist.
Tax Deadline – Key Points:
..On March 20, 2020, the Internal Revenue...more
3/26/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Office Closures ,
Popular ,
Relief Measures ,
State of Emergency ,
Tax Court ,
Time Extensions
The IRS has published a Revenue Ruling and FAQs clarifying some long-standing virtual currency questions.
On October 9, 2019, the US Internal Revenue Service (IRS) issued its first guidance on the tax treatment of...more
Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct.
On August 6, 2018, the US Tax Court decided...more
LB&I has announced compliance initiatives regarding the Section 965 Transition Tax, Repatriation via Foreign Triangular Reorganizations, and Virtual Currency transactions.
Key Points:
..The IRS continues its efforts to...more
Guidance eases tax filing burdens on medical device manufacturers.
On February 24, 2016, the Internal Revenue Service (IRS) published informal guidance on the suspension of the Medical Device Excise Tax through an update...more
While FBAR reporting rules are frequently misunderstood, US persons have several options to correct mistakes, before the government learns of the non-compliance.
June 30th is the annual deadline for filing a Foreign...more
The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad.
The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more
4/16/2015
/ Banks ,
BSI SA ,
Department of Justice (DOJ) ,
FATCA ,
FFI ,
Foreign Banks ,
IRS ,
Non-Prosecution Agreements ,
OVDP ,
Swiss Banks ,
Tax Evasion
On Sept. 9, 2014, in U.S v. Robert Bandfield et al., federal prosecutors in the Eastern District of New York announced the indictment of a U.S. citizen and others, including offshore corporate service providers (CSPs) and...more
Indictment demonstrates the strength of US law enforcement efforts to combat offshore fraud and is the first to charge a FATCA violation.
On September 9, 2014, in US v. Robert Bandfield, et al., federal prosecutors in...more
9/16/2014
/ Conspiracies ,
Enforcement Actions ,
FATCA ,
FATCA Timeline ,
Fraud ,
Indictments ,
Investment Adviser ,
Money Laundering ,
Offshore Companies ,
Reporting Requirements ,
Securities Fraud ,
Tax Evasion ,
Third-Party Service Provider
The changes give taxpayers who mistakenly failed to report foreign assets a simpler path back to tax compliance.
On June 18, 2014, the Internal Revenue Service (IRS) announced major modifications to the terms of its...more
Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers.
On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss...more
United States Department of Justice issues further information on amnesty program for Swiss banks, including details on the selection of an Independent Examiner.
On November 5, 2013, United States Department of Justice...more